Privacy Policy and Terms of Service

At Cryptoqo we value privacy. It is Cryptoqo’s policy to respect your privacy regarding any information we may collect from you across our website. We only ask for personal information that is required legally to provide a service to you. We collect it by fair and lawful means, with your knowledge and consent. You can contact us with questions on why we’re collecting it and how it will be used. We only retain collected information for as long as necessary to provide you with your requested service. What data we store, we’ll protect within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. We don’t share any personally identifying information publicly or with third-parties, except when required to by law. Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and practices of these sites, and cannot accept responsibility or liability for their respective privacy policies. If you refuse our request for your personal information, we may be unable to provide you with some of your desired services. Your continued use of our website will be regarded as acceptance of our practices around privacy and personal information. If you have any questions about user data and our policy, feel free to contact us. This policy is effective as of 1 November 2020.

AML Policy

Cryptoqo BV ("Cryptoqo" / "Company") has a zero-tolerance policy for money laundering, the financing of terrorism or any other form of illicit activity. We are committed to implementing policies, procedures and controls shaped by the best industry practices and the most effective anti-money laundering standards applied in the Kingdom of the Netherlands and worldwide. These rules apply to, without exception, all employees of the Company, contractors, and consultants. The AML policy is based on the information provided by CRYPTOQO B.V. and the regulations in the Kingdom of the Netherlands (as of July 2019) regarding the prevention of money laundering and the financing of terrorism. It is the sole responsibility of CRYPTOQO B.V. to carry out the provisions of this AML and KYC policy. This policy states that CRYPTOQO B.V. carries out their own research with regard to anti-money laundering regulations and acts according to these regulations.

The purpose of this document is to provide the Company's partners, clients, vendors, contractors, employees, regulators, law enforcement and other concerned stakeholders with a high-level overview of the Company's AML/CTF compliance regime elements and procedures. By no means this document shall not be read as an entire set of all policies, procedures and controls in place implemented by the Company for prevention of money laundering, financing of terrorism and other forms of illicit activity.

AML and KYC policy CRYPTOQO B.V.

Chapter 1: General provisions

  1. CRYPTOQO B.V offers e-commerce plug ins for businesses to integrate cryptocurrencies into their store. Clients can run these plug ins on various platforms and withdraw as they please. This document is applicable to all transactions where virtual currencies are accepted by CRYPTOQO B.V. as a means of payment.
  2. This policy aims to counter money laundering and/or terrorist financing through the services of CRYPTOQO B.V. It outlines the procedure by which CRYPTOQO B.V. complies with the fourth anti-money laundering directive (EU 2015/849, hereafter: AMLD-4) and the Dutch Law for prevention of money laundering and terrorist financing (hereafter: WWFT).
  3. CRYPTOQO B.V. does not exchange cryptocurrencies for fiat currencies and vice versa.
  4. Chapter 2: Definitions

  5. Virtual currencies are defined as: a digital representation of value that is not issued or guaranteed by a central bank or a public authority, is not necessarily attached to a legally established currency and does not possess a legal status of currency or money, but is accepted by natural or legal persons as a means of exchange and which can be transferred, stored and traded electronically;
  6. Transactions are defined as: a client payment through virtual currencies for the products and services offered by e-commerce stores. The amount of the transaction is always calculated in Euro (€).
  7. Chapter 3: Conditions for the acceptance of virtual currencies

  8. CRYPTOQO B.V. handles virtual currencies as a means of processing payments for transactions that do not exceed € 7.500, notwithstanding whether that transaction is carried out in a single operation or in several operations which appear to be linked.
  9. For all transactions, CRYPTOQO B.V. asks clients to submit their first and last name, phone number, e-mail, and country of residence as well as passport information for compliance.
  10. This AML and KYC policy forms part of the general terms and conditions of CRYPTOQO B.V. In accepting the terms and conditions of this AML and KYC policy, the client agrees and confirms the following:
    • a. That the virtual currencies used as a means of payment do not derive from a criminal offence, and that his or her virtual currencies have not been, and will not be employed for terrorist financing;
    • b. That CRYPTOQO B.V. maintains the right to reject payments in virtual currencies without given reason;
    • c. That CRYPTOQO B.V. may request additional information from the client in order to verify that his transaction does not exceed the threshold of € 7.500 as set out in article 6;
    • d. That CRYPTOQO B.V. processes BTC on its own servers;
    • e. That the client agrees that their data is processed by Cryptoqo B.V. in order to complete the transaction;
    • f. That CRYPTOQO B.V. may monitor the IP and/or MAC address of the client in order to ensure that he does not exceed the threshold set in article 6;
    • g. That the client conducts the transaction as a natural person and on his own behalf, and that he does not conduct the transaction in the name of a third (legal) person, or as an ultimate beneficial owner of a third legal person, or as a trustee;
    • h. That the client does not have his country of residence in a state with strategic deficiencies in their national AML and KYC regimes, as published on the website of the FATF and in Annex III, article 3 of AMLD-4;
    • i. That the client is not a politically exposed person (PEP), a family member of such a person, or a person known to be a close associate of a politically exposed person as mentioned in article 2 of the Dutch executive decision on the Dutch Law for prevention of money laundering and terrorist financing (hereafter: Uitvoeringsbesluit WWFT).
  11. Chapter 4: Transactions and business relation with the client

  12. If a transaction or related transactions exceeds € 7.500, CRYPTOQO B.V. will reject the transaction and request the client contact us for higher tier KYC checks.
  13. CRYPTOQO B.V. monitors all transactions that are conducted. If CRYPTOQO B.V. suspects that the transaction may facilitate money laundering and/or terrorist financing, CRYPTOQO B.V. immediately ends the business relation with the client and rejects the transaction(s).
  14. CRYPTOQO B.V. is not an entity under AMLD-4 or the WWFT. CRYPTOQO B.V. is therefore not obliged to report suspicious transactions to the Financial Intelligence Unit Netherlands (FIU).
  15. Under future laws such as the AMLD-5 and the Dutch implementation of the AMLD-5 the payment processing of virtual currencies to fiat currencies will fall under the provisions of the WWFT. Therefore, clients may in the future have provide more details in order to pay with virtual currencies. In addition to the above document CRYPTOQO B.V will define the following terms in regards to understanding the KYC/AML policy. It is up to the client to ensure they have thoroughly read all aspects of the policy before agreeing to the services provided.

Cryptoqo B.V understands money laundering as:

  • the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person's action;
  • the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;
  • the acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such an activity;
  • participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points (a), (b) and (c).

Terrorist financing provides funds for terrorist activity. From legal standpoint it means the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or in the knowledge that they are to be used, in full or in part, in order to carry out any of the offences within the meaning of Articles 1 to 4 of Council Framework Decision 2002/475/JHA. Terrorist activity has as its main objective to intimidate a population or compel a government to do something. This is done by intentionally killing, seriously harming or endangering a person, causing substantial property damage that is likely to seriously harm people or by seriously interfering with or disrupting essential services, facilities or systems.

PEP Definition and Screening

Politically Exposed Persons ("PEP") (as well as their families and persons known to be close associates, as described below) are required to be subject to enhanced scrutiny by reporting entities. This is because international standards issued by the Financial Action Task Force recognize that a PEP may be in a position to abuse their public office for private gain and a PEP may use the financial system to launder the proceeds of this abuse of office.

PEP means a natural person who is or who has been entrusted with prominent public functions including:

  • head of State;
  • head of government;
  • minister and deputy or assistant minister;
  • a member of parliament or of a similar legislative body;
  • a member of a governing body of a political party;
  • a member of a supreme court;
  • a member of a court of auditors or of the board of a central bank;
  • an ambassador, a chargé d'affaires and a high-ranking officer in the armed forces;
  • a member of an administrative, management or supervisory body of a State-owned enterprise;
  • a director, deputy director and member of the board or equivalent function of an international organisation, PEPs do not include middle-ranking or more junior officials.
  • Family member of a PEP means the spouse, or a person considered to be equivalent to a spouse, of a PEP or local PEP;
  • a child and their spouse, or a person considered to be equivalent to a spouse, of a PEP or local PEP;
  • a parent of a PEP or local PEP.

Person known to be close associate of a PEP means a natural person who is known to be the beneficial owner or to have joint beneficial ownership of a legal person or a legal arrangement, or any other close business relations, with a PEP or a local PEP; and a natural person who has sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the de facto benefit of a PEP or local PEP.

Sanctions Screening

Dealing with persons against which imposed international sanctions poses a great risk to the Company, its directors, officers and owners.

The Company will perform sanction screening of its customers on the same matching rules, as for PEP screening.

The Company will perform screening, at minimum, against the following sanctions lists:

  • UN Sanctions;
  • EU Sanctions;
  • Sanctions administered by the Office of Financial Sanctions Implementation ("OFSI-UK")
  • Sanctions administered by the Office of Foreign Assets Control ("OFAC-US");
  • Sanctions imposed under the International Sanction Act.
  • All matches (true hits) will be escalated to a Compliance Officer for further action and processing.